Managing FICA

Unit 1: Understanding money laundering, terrorist financing and proliferation financing

• Show an understanding of how an accountable institution is to be registered on the goAML platform, in respect of main offices or branches.
• Show an understanding of how to deal with changes to information on the goAML and whose responsibility it is to see to the changes.
• Show an understanding of what is to happen when an accountable institution is sold or transferred.
• Show an understanding of who is to be registered on the goAML platform – FICA Compliance Officers and/or Money Laundering Reporting Officers.
• Differentiate between a FICA Compliance Officer (CO) and a Money Laundering Reporting Officer (MLRO).
• How to register a FICA Compliance Officer and a Money Laundering Reporting Officer within a delegation structure

Unit 2: Regulation

• Discuss the purpose of the Financial Intelligence Centre Act 38 of 2001 (“FICA”), the Prevention of Organised Crime Act 121 of 1998 (“POCA”) and the Protection of Constitutional Democracy Against Terrorism and Related Activities Act 33 of 2004 (“POCDATARA”).
• Explain the functions of the Financial Intelligence Centre (“FIC”).
• Describe the purpose and functions of the Financial Action Task Force (“FATF”).
• Understand the FICA compliance that Supervisory Bodies may incorporate into their requirements.
• Understand who are accountable institutions and reporting institutions, and the difference between the two

Unit 3: Compliance

• Describe the requirements for accountable institutions and reporting institutions relating to registration with the FIC.
• Explain the obligations of accountable institutions regarding the implementation of a Risk Management and Compliance Program (“RMCP”).
• Identify the duties of a FICA Compliance Officer.
• Describe the circumstances under which FICA prohibits the conclusion of a business relationship or single transaction with a client.
• Indicate the requirements relating to the identification of clients and understanding of the business relationship.
• List the circumstances in which additional CDD must be conducted with regards to different types of clients.
• Distinguish between the record keeping requirements for CDD records and transactions records.
• Discuss the operational allowances relating to record keeping, according to the FIC requirements.
• Explain the difference between Customer Due Diligence and client screening.

Unit 4: Reporting and record-keeping

• Define the following reports that must be submitted to the FIC:
  • The property associated with terrorist and related activities report (“terrorist property report”);
  • The cash threshold report;
  • The suspicious or unusual activity report;
  • The suspicious or unusual transaction report;
  • The terrorist financing transaction report;
  • The terrorist financing activity report; and
  • The international funds transfer report.
• Explain the manner of reporting, responsibilities for reporting and reporting timelines of all the reports mentioned above.
• Understand the compliance and enforcement measures enacted by FICA to ensure that all relevant parties comply with the respective provisions of FICA and its incidental legislation.

Unit 5: Registration and Appointment

• Show an understanding of how an accountable institution is to be registered on the goAML platform, in respect of main offices or branches.
• Show an understanding of how to deal with changes to information on the goAML and whose responsibility it is to see to the changes.
• Show an understanding of what is to happen when an accountable institution is sold or transferred.
• Show an understanding of who is to be registered on the goAML platform – FICA Compliance Officers and/or Money Laundering Reporting Officers.
• Differentiate between a FICA Compliance Officer (CO) and a Money Laundering Reporting Officer (MLRO).
• Show an understanding of how to register a FICA Compliance Officer and a Money Laundering Reporting Officer within a delegation structure.

Unit 6: Risk-based Approach

• Understand what is meant by a “risk-based approach”.
• Discuss concepts such as:
  • risk,
  • money laundering, terrorist financing and proliferation financing risk,
  • risk management,
  • risk identification,
  • risk assessment,
  • risk mitigation.
• Be empowered to draft a Regulatory Risk Register.

Unit 7: RMCP

• Show an understanding of the prescribed content of the Risk Management and Compliance Programme (“RMCP”), including:
  • Customer due diligence measures.
  • Reporting.
  • Record keeping.
  • Implementation in general and in foreign branches.
  • Other matters such as the screening of employees.
• Be empowered to draft an RMCP

Unit 8: Employees and Reporting

• Discuss the screening of employees for competence and integrity as well as against the FIC’s Targeted Financial Sanctions List.
• Discuss the consequences of failure to screen employees.
• Discuss the consequences of appointing a person or retaining an existing employee who appears on the FIC’s TFS List.
• Discuss the training of employees, including:
  • The content of training.
  • The extent of training.
  • The timing of training.
  • Assessments.
  • Training registers.
• Show an understanding of the internal reporting of an activity or transaction that gives rise to the obligation to make a report in terms of FICA.

Unit 9: FIC Inspection

• Show an understanding of:
  • FIC inspections.
  • FIC inspectors.
  • The rules of inspection.
  • The powers of FIC inspectors.
• Understand what will be expected at a Financial Intelligence Centre or supervisory body inspection.

Unit 10: FICA in a Nutshell

Summary of Unit 1 – 9

Learning material will be made available on the Learning Management System (LMS).

Students will have access to interactive, online learning material developed by an industry expert which will include relevant additional resources.

Students can register online (www.mbse.ac.za )at any time of the week (Monday to Friday).

Students will receive confirmation of registration and be allowed access to the learning material, once the required payment for the course has been made.

The course can be completed in 5 hours. The student will have access to the course for 6 months

Students will receive a Digital Certificate of Completion once the Final Assessment has been successfully completed. A pass mark of 60% is required for the Final Assessment.